Response to Draft ABC of UGC: Establishment and Operationalisation of Academic Bank Credit Scheme in Higher Education Regulations

Click here to see the email submitting AIPSN response to UGC

Click here to see the pdf of the AIPSN response to UGC

5th Feb 2021

AIPSN Response to Draft UGC (Establishment and Operationalisation of Academic Bank Credit (ABC) Scheme in Higher Education) Regulations 2021

The UGC during the pandemic period has brought out the draft regulations to establish and operationalise the Academic Bank Credit Scheme on 21 Jan 2021 and has asked for feedback from stakeholders by 5th Feb 2021 via the gmail id abcregulations2021@gmail.com

The response from AIPSN is given in two parts: a) Procedural inconsistencies and b) Long term deleterious impacts

A. Procedural inconsistencies

  1. A democratic exercise has once again been hijacked and made a mockery of in a process that has become familiar. Force a bill, act, ordinance, directive without any discussion to plead that it is good for the nation, farmer, academic, student, teacher worker. The farm laws have met unprecedented resistance. But that has also given the backdrop to take attention away from matters related to other issues. It is for this reason that the government released the Science, Technology, Innovation Policy document on 31st Dec 2020 with only 3 weeks to respond- the date being extended by eleven more days under demand. The same has now happened with this UGC ABC draft regulations being put up on 21st January on the UGC website with the last date to respond is 5th February, 2021 with not even a press announcement for such an important document!”
  2. The question naturally arises what is the urgency? There has to be more time given especially as colleges and universities are not fully functioning due to the pandemic. As it is a scheme that is meant for students, the students need to be involved in the discussion. The time could be given till 30th April 2021 and then the responses can be made public before a new draft is circulated.
  3. There is no postal address and contact person. The online access and internet access in India is not uniform across the country and in different social strata. A postal address and contact person must be specified for students and others to respond offline also.
  4. It is surprising that UGC has chosen a gmail id for soliciting responses rather than use an official government email id or website for the responses. If UGC does not have this capability even, how is it going to operationalise the online Academic Bank Credit? Or is it an indication that ABC will be outsourced to a private party?                                                                                                                                 B. Long term deleterious impacts
  5. The Academic Credits are a way to standardize and make education like an assembly line process borrowed from the predominantly commercial education system. The major limitation of the credit system is that it fragments knowledge as has been acknowledged in the World Bank report on American Credit System in Higher Education brought out in 1992. What we really need is a discussion on the need and the modification needed in the functioning of the credit system.
  6. In India the Choice Based Credit System (CBCS) is poorly functioning at most in a token manner and mostly a disaster in many Universities and colleges. It has been a failure considering that it does not motivate the student nor does it go towards enriching knowledge skills or broader understanding. Even within a University or College there is no possibility of transferring credits. Building on this to bring about an external centralized institution called the Academic Bank Credit for trying to transfer credits across institutions is clearly not based on the reality of what exists.
  7. In the US which pioneered the use of the credit system, ccompleting the first two years of a degree at one institution, usually a community college, and then moving to another, is very common. There is a National Institute for study of Transfer Student that has tried to create website to facilitate transfer. Most States of the USA have a range of approaches from informal efforts of transfer students to more formal institution-based agreements or state-mandated policies. But there is no centralised Credit Bank in the USA that is involved in the transfers.
  8. In China the credit transfer and inter institutional course selection or student exchange has been limited to smaller universities and those in geographical proximity. This was initiated as part of the Chinese National Outline for Medium and Long-term Education Reform and Development (2010-2020). The goal was mainly towards life long education as in Korea. A study of four such initiatives in China concluded “procedures and systems related to credit transfer need to be formulated taking into account China’s actual situation in regard to college entrance and school registration management, thereby ensuring the reliability and credibility of credit transfer”. The Chinese systems do not involve any Centralised Credit Bank.
  9. The most successful credit transfer system in place is the European Credit Transfer System. It is a central tool in the Bologna Process, which aims to make national education systems in Europe more comparable internationally. The ECTS grading systems do not replace the local grading systems, but they provide a supplement to local grades, for example, on a transcript of records. It simply provides equivalences and makes degree programmes and student performance more transparent and comparable across all countries that are members of the European Higher Education Area (EHEA). The ECTS credit system does not involve any Centralised Credit Bank.
  10. The Academic Credit Bank System (ACBS) was started in Republic of Korea in 1998 to augment a lifelong learning. It is a degree granting body. A recent review in 2019 has indicated that the system given the social stratification does not assure equality of outcomes though it theoretically provides equality of access. If this is the case in Korea, in the highly stratified Indian society full of inequities which has also been pointed out by Babasaheb Ambedkar, this current initiative of UGC Academic Bank Credit will only further exacerbate the inequalities of outcomes.
  11. The ABC of UGC is a virtual bank (see 5.1 ‘ABC shall be a digital/virtual/online store-house entity of credit data base of HEIs with students as its stakeholders’). It is not a degree granting body (see 5.4. ABC shall not be, by itself, a Degree-awarding organisation; The Statutory degree-awarding power shall continue to be vested with the eligible HEIs which have registered with ABC). This therefore does not make it suitable as a vehicle for lifelong education. Ultimately the student will be forced to run around between institutions to get the degree for which the credits are entitled as the ABC will need the HEIs to communicate the credits to the ABC (see 6.1 However, ABC shall not accept any credit course document directly from the students and shall entertain such documents as valid only when they are transmitted by the respective, registered HEI awarding the credits).
  12. A fee will be charged to the student to keep the credits in the ABC (see 8.11 ‘There would be a credit processing fee to be paid by the registering student to ABC for maintaining the student’s Academic Bank Account and related functions. It would be fixed appropriately to encourage maximal usage of the ABC scheme by students’). No mechanism has been spelt out to keep the course fees affordable for economically and socially underprivileged students. This would be a further burden on the students and would work against the utilisation by the marginalised groups further increasing the educational divide.
  13. The Higher Education Institutions (HEIs) which are part of the ABC system are those which have the NAAC grade of ‘A’. Only 205 out of a total of 875 Universities are eligible which is just 23% of the Universities. In the case of colleges 1844 have greater than A grade out of total 38498 colleges, that is just 5% are eligible. This scheme is elitist in concept and implementation.
  14. In theory, this UGC ABC sounds as if it is very useful and revolutionary. In reality it will not help first generation students. It will benefit 3rd or nth generation learners as they will be able to navigate the system better both conceptually and financially. City based students would fare better in using this ABC than rural students. In general, this UGC ABC will increase the educational divide in society along caste, minorities, and rural fault lines.
  15. AIPSN calls upon UGC to abandon this flawed Centralised Academic Bank Credit and instead initiate a discussion on the enabling the credit system to first function properly for even in the words of Abbott Lowell who was President of Harvard University in USA: “The real unit is the student. He is the only thing in education that is an end in itself”.

For clarifications contact:

S. Krishnaswamy 9442158638

P. Rajamanickam, General Secretary, AIPSN

gsaipsn@gmail.com, 9442915101 @gsaipsn

On the draft STIP2020: Need for a people-centered and future-oriented STIP based on reality

click here to see the Gmail submission of AIPSN Response to draft STIP2020

click here for the AIPSN-response-DraftSTIP2020-30Jan2021 in English

 

30Jan2021

All India Peoples Science Network (AIPSN) Response

 

On the draft STIP2020:

Need for a people-centered and future-oriented STIP based on reality

  1. During the ongoing pandemic, the Science Policy Forum and Department of Science and Technology initiated a series of discussions in different tracks to discuss various parts for formulating a draft STIP2020. On Dec 31st a draft was released in English online and a feedback response date of 25th Jan was given. Two days before the date, the deadline was extended to 31st Jan.
  2. In the economic transformation of Japan, South Korea and China their policies relating to Science, Technology and Innovation played a significant role in these countries’ development with advanced capabilities in technologies of the second and third industrial revolutions, poised to also develop such capabilities in 4th generation technologies expected to dominate the global economy over the next two decades. Several other Asian countries such as Singapore and Taiwan have also developed advanced manufacturing capabilities and know-how. All these nations have followed what we may broadly call a self-reliant pathway in S&T, consciously investing in developing their own knowledge, industrial and human resource capabilities over the years, as against depending on “Western” MNCs or companies for this. In the Global Innovation Index China now a rank 14th for the 2nd time in a row and remains the only middle-income economy in the GII top 30. India is at the 48th position. This follows the consistent growth of Gross Expenditure on R&D (GERD) with respect to the GDP in the case of China that grew from 0.6 in 1996 to 2.2 now, while in contrast India has remained hovering around 0.6 since 1996. GERD of the “Asian Tiger” economies follows a similar trajectory. It is also important to highlight the fact that China has used per capita GDP as a metric to measure its progress, thereby placing emphasis on the share of its working population in growth, rather than just GDP as India and many other countries do.
  1. The biggest weakness of draft STIP 2020 is that the policy is not rooted in the economic and industrial scenario of the country, and the direction in which these are visualized to transform over the next, say ten to fifteen years. Without such a vision, draft STIP2020 is cast in a vacuum. Further, the draft STIP2020 does not take cognizance of the present state of Science, Technology and Innovation in India, and put forward a policy that starts from where we are and leads to where we want to go. Similarly, the suggestions proposed do not also reckon with the institutional and systemic weaknesses or strengths. In this context, the very feasibility and utility of the draft STIP2020 are open to question, however nice this or that proposal sounds. Incidentally, STIP 2013 envisioned positioning India among the top 5 global scientific powers by 2020. Do we then presume that India has achieved that and now moves towards the top 3?
  1. A well thought out and designed policy that is sensitive to the needs of not only the people of India but of the world can make a tremendous difference. However, for inclusive and sustainable growth, it is important to first chart the practical steps for effective implementation of S&T policies. Such an approach is needed for balanced and integrated development taking into account the social and environmental aspects. In order to do this, it is important to first ensure the penetration of basic infrastructure of roads, electricity, communications and internet, water, public health, education and skills, to all parts of the country. Just as India’s R&D expenditure has historically been miserably low, so too has India’s investment in the health and education of the majority of its population and potential work force.  No less is the importance of a federated approach to take into account the geographical and developmental diversity amongst the States and Union Territories of India. A rigid one shoe fits all approach will not be useful. There has to be inbuilt flexibility in terms of structures, funding and implementation considering the developmental and infrastructural variations in different regions.
  1. The draft STIP2020 is not an authentic national STI policy. At best, it is like a policy for the Department of Science and Technology (DST). A transformational STI policy needs to bring on board all the government departments of the union Government, the state governments and the public in a collaborative mode for the formulation of STIP 2020 draft.
  1. The vision of the policy as mentioned “to build individual and institutional excellence in STI with the aspiration to achieve the highest level of global recognitions and awards in the coming decade” is completely flawed. One cannot have a national policy based only on awards and recognitions: if India does outstanding science and develops novel advanced technologies, awards and recognitions will follow. As the Nobel Laureate Venkatraman Ramakrishnan has said “Science flourishes when people are free to question authority”. But that cannot be built into a policy. It is an academic, research and society-wide culture and part of the scientific temper which is encouraged by our Constitution.
  1. The draft policy keeps referring to undefined Traditional Knowledge Systems and in one place links it with heritage. This along with references to undefined grassroots innovations is in dissonance with the vision to position India among the top three scientific superpowers in the decade to come. However, highlighting these in the draft STIP2020, in the context of what is currently being done in India under the rubric of these terms, does pave the way for significant funding for spurious and inefficacious efforts, often pulling in an opposite direction to the desired future-oriented STI.
  1. The draft STIP2020 is astonishingly filled with a plethora of new Institutions and Funding Schemes: the Capacity Building Authority, the STI Policy Institute, the overarching Strategic Technology Board, a Strategic Development Fund, a national STI Financing Authority, an STI Development Bank, the national STI governance mechanism, the National STI Observatory, Indian Science and Technology Archive of Research (INDSTA), Advanced Missions in Innovative Research Ecosystems (ADMIRE), a centralized database on all forms of Financial Incentives, and Inter-State Science, Technology and Innovation Council (IS-STIC). While it is necessary that funding mechanisms be centrally coordinated, the structural framework along with the control structure also needs to be decentralized in order to take into account the spirit of cooperative federalism envisaged in the Constitution of India.  These numerous new Institutions would only lead to additional bureaucratic structures in an already top-heavy science administration, draining even more funds from actual research. There is also no point creating new institutions and funding schemes without examining the problem of non-functioning or malfunctioning of existing ones.  It is ironic that these suggestions for new Institutions come at a time when the government is engaged in closing down many S&T Institutions and driving them to raise their own funds, therefore reducing the amount of research done, showing again how distanced the draft STIP2020 is from ground realities.
  1. The draft STIP2020 talks of attracting Foreign Direct Investment (FDI) in STI, reduction in corporate tax rates for foreign MNCs, fast track clearances, easing land acquisitions, adequate means for incorporating FDI etc. to be explored on a need basis. This is definitely detrimental to public  sector research in agriculture  aiming  to strive  for food  self sufficiency, security and especially nutritional security. Self-reliant STI can certainly not be built through FDI or by foreign MNCs who may manufacture in India but will not transfer technologies as experience hitherto has amply shown. Experience of Japan, S.Korea and China is exactly the same: they embarked on a self-reliant path precisely because MNCs and Western companies will never part with their technologies, since they know full well that it is knowledge and technology, which controls industry and the economy. This is yet another cardinal mistake in the draft STIP2020; following the present Governments idea that manufacturing in India by foreign companies/MNCs directly or through FDI in junior Indian partners, is also “Make in India” and also represents Atma Nirbhar Bharat. Nothing could be further from the truth. The draft STIP2020 is extremely permissive to imports, and by this route it plans to achieve ” Atmanirbhar Bharat” and India’s emergence as the third global power in STI! And for that, science is now given a new role: “S&T for diplomatic benefits” and “diplomacy for S&T development”! In this draft STIP2020, the Indian Diaspora are to serve as conduits in the mercantilist exploitation of science, in which India’s intellectual resources, like her scientists, will be the basic inputs in this Atmanirbhar Bharat’s Global Assembly Line.
  1. The long-term and continuing reluctance of the private sector in India to invest in R&D is notorious but is not meaningfully addressed in the draft STIP2020. Much of this is due to Indian corporates’ preference to take the easy route of foreign collaboration or technology imports repeatedly incentivized by industrial and taxation policies of successive governments, even further promoted by the current emphasis on FDI as the major engine of industrial and technological development. Minor policy incentives or inducements will not change this, and a thrust for genuine self-reliance is a must.
  1. The draft STIP2020 also provides an escape clause for the Central Government from the need for enhanced investments in R&D by proposing that all other stakeholders such as State governments, PSUs, SMEs, private sector, Universities, Research Institutions and so on would be required to set aside earmarked funds for R&D. This is a futile and sub-optimal exercise and would only lead to ineffectual “R&D” on paper, merely to satisfy some bureaucratic requirement. In the absence of mission-oriented R&D programmes at scale, the goal of transformative R&D to take India into a leading position in the 4th industrial revolution would remain a pipedream.
  1. There is no meaningful discussion of employment in a potentially changed capital and technology-intensive industrial scenario, and how the draft STIP2020 proposes to address this issue. There is therefore no mention of the working people, farmers, workers, migrants, unorganized workers, rural unemployed and under-employed. Nor is there any indication of how the STI is going to benefit and take them along in the process of inclusive and sustainable growth. This begs the question as to who this draft STIP2020 bell tolls for?
  1. Another big miss in the draft STIP2020 is the absence of addressing societal goals that can be targeted through S&T and by promoting scientific temper, issues that were emphasized in the Scientific Policy Resolution 1958 (SPR1958).Even in its mention of the SPR1958 document, the draft STIP2020 does not mention these aims of the SPR1958 and limits itself to stating that “S&T were seen as vehicles for the onward journey towards socio-economic transformation and nation building”. The role that S&T can play in alleviating hunger (India stands 102 among 117 countries in World Hunger Index), combating disease, ensuring health, hygiene, housing, employment and making the reach of science equitable are not addressed at all in the document.
  1. The draft STIP2020 is anything but what it says: “It is to be noted that the new STIP policy revolves around the principles of being decentralized, evidence-informed, bottom-up, experts-driven, and inclusive.” There are a lot of hollow claims of producing an evidence-driven, inclusive and bottom-up policy process steered and coordinated for the well being of the nation and its people with socio-economic and environmental considerations. The rambling draft policy makes all the right noises but lacks foundations of reality making it a catch all bucket list which without the grounding will remain wishful thinking. It is essential to cut the fluff and make it lean but meaningful.
  1. A major appreciative aspect of the draft STIP2020 is the very mention of LGBTQ+ and all that follows. But again it is dampened by the lack of specifics and arriving at how the changes can be made. The other aspect that is appealing is the talk of Open Science but the sheen is lost, due to not trying to figure out why it has not progressed, as needed, so far.
  1. The importance given to Science Communication is welcome, but it is disappointing to see the stress on scientists rather than on imbuing the lay citizen with scientific temper, critical thinking and the world view of science. It is puzzling that, rather than acknowledge and build upon the existing almost 40 year old people’s science movements in the country committed to and involved with activities towards this goal; this policy glibly seeks to “create” new science movements. Civil society organizations should be left to themselves and supported, but government-created “science movements” would be self-defeating and work against developing critical thinking which often requires looking at governmental S&T policies with a critical eye.
  1. The STIP will affect all sections of the public and, as mentioned in the draft STIP2020, it is meant to be inclusive. Moreover, it also intends to make science literature available in all languages and geographic regions. So a good starting point will be to make the draft STIP2020 available in all the Scheduled languages in the Constitution of India so that the public including researchers at all levels can meaningfully understand and discuss it to come forward with suggestions.
  1. There is no particular urgency to have the STIP brought out within the coming months especially in the time of the pandemic. It may therefore be a good idea to revise the Draft in a transparent manner taking into account comments received, and the revised STIP then placed before parliament allowing for scrutiny by the Parliamentary Standing Committee on S&T.

 

AIPSN demands for transforming the draft STIP2020

into a people-centered and future-oriented STIP based on reality:

 

a) The draft STIP2020 be made available officially on the website in all the Scheduled languages and propagated through social media and TV. After that is made available at least two months period should be given for wide dissemination and involvement in discussions. 

b) There should be a provision for giving feedback through hard copies also apart from only online as online access is still limited in the country. One contact person should be mentioned to ensure that the hard copies will be received correctly. 

c) All the suggestions received, as hard copies and online, must be put into an indexed publicly available online database so that there can be cross checking about incorporation in the STIP. 

d) The draft STIP2020 has to reduce the rhetoric and make it more realistic 

e) The NEP has not been debated in the Parliament. Therefore, endorsing or linking NEP in sections of the STI is not democratic. It is important to involve the Parliament in the STI through formation of a Parliamentary Standing Committee for STI. This is also one of the recommendations by UNESCO for countries to democratise the STIP. 

f) The many structures that are envisaged in the STI need to be decentralised, not in funding but in functionality and structure, taking into account the cooperative federalism which is the spirit of the Constitution. 

g) The four decades old popular science movements and some even older science popularization organizations in the country need to be acknowledged and built upon rather than artificially “creating” new science movements to act at the behest of the government. 

h) There were only limited online attempts to involve or seek the opinions of the wide thriving S&T community in the country. There needs to be more engaged consultations with such S&T communities distributed across the country to evolve this national policy. 

30Jan2021

 

For clarifications contact:

  1. Krishnaswamy 9442158638
  2. Rajamanickam, General Secretary, AIPSN

gsaipsn@gmail.com, 9442915101 @gsaipsn

 

 

Stop Monopoly Publishers Efforts  To Deny Public Access to Scientific Publications

Stop Monopoly Publishers Efforts To Deny Public Access to Scientific Publications

click here English pdf SciHub-AIPSNStatement29Dec2020FinalP

Click here for Hindi version pdf of SciHub-AIPSN statement

click here for Kannada version pdf of SciHub-AIPSN Statement

Click here for Odia version pdf of SciHub-AIPSN statement

Stop Monopoly Publishers Efforts To Deny Public Access to Scientific Publications

Three major academic publishers—Elsevier Ltd., Wiley India Pvt. Ltd., American Chemical Society— have filed a petition in Delhi High Court asking for dynamic blocking of Sci-Hub and Libgen in India. SciHub is the first site to allow mass and public access to research publications while LibGen allows access to books. These websites help Indian scientists, teachers and students to freely access and download research publications and books even if they are behind paywalls.

Why are Elsevier, Wiley and American Chemical Society filing this suit? Journal publishing has one of the highest profit margins amongst different sectors and is now a 10 billion USD industry. The profit margin from journal publishing is nearly 40% or twice that of Google! Three publishers who have filed this case together publish 40% of scientific publication and control more than 50% of the publications in science and social sciences worldwide.

Knowledge and its access are accepted under the Universal Declaration of Human Rights as a fundamental human right. In reality, it is denied by the current system where a group of publishing monopolies make super-profits from the work. It is scientists who volunteer their time to both referee the papers and uphold quality, and also sit on editorial boards that manage the publishing process. These publishers have thus no contribution whatsoever to the research writing, refereeing and editing of the papers but enjoy the fruits of the mental and physical labour of researchers. Ironically, even those who produce the content, have to pay for accessing their own work. This is the business model of scientific publishing which is bad for science, while these publishers reap huge profits.

Alexandra Elbakyan, a young Kazakhstan science scholar, started Sci-Hub due to lack of access for the bulk of science scholars to good quality journal articles. Under the cases filed in the US, she can be arrested anywhere and transported to the US to face trial and a lengthy prison sentence. It is not an accident that the case filed in Delhi High Court asks for her address to be disclosed so that the full might of the US and its extra-territorial reach can be used to stop her.

Even well-off educational institutions such as the University of California in the US, are finding it difficult to pay the huge costs charged by these monopoly publishers and have refused to pay for the subscriptions. Significantly, researchers in Universities and Institutes who have access to these publications including the US, access SciHub, as it is much easier to download papers as a one-stop place with about 80 million papers.

An analysis in 2016 showed that Indian scholars downloaded about 7 million papers in one year using SciHub. Without SciHub, it would have cost the Indian Universities or students around 200-250 million USD, which neither the students nor the universities have.

Open Access journals allow people to read and download content free but the content producers – scientists and researchers or their institutions or funding agencies — have to pay the journals to be published. Instead of access, the problem for poorer countries and universities shift to the ability of its researchers to pay for being published. Moreover, only 20% of the research content today is in such open access journals.

The three publishers have filed similar suits in other countries as well. But in India, it is not only a case of publishers’ vs SciHub/Libgen. Here there is a huge community of students, teachers, research scholars and scientists whose access to these journals and books would virtually end if the publishers get their prayer in court for dynamic blocking to these sites. There will be serious long term consequences to science and education in India.

It might be believed that Sci-Hub has no legal case in India. This is not true. Sci-Hub does not charge any student or researcher for downloads — it is a free service. So it is not profiting from making such papers available. Secondly, Indian copyright law has exceptions for education and research. It is for the Courts to decide whether Sc-Hub’s use by research scholars in India constitutes a valid use of the copyright exceptions, similar to what was argued and decided by the courts in the Delhi University photo-copying case. Blocking these websites will also mean that access to those publications which are under open access or not published by these publishers will also get blocked.  Finally, these copyright holders are sitting on content some of which is more than 60 years old and free from copyright in India. Yet we still have to pay money to access even this content.

The case filed by the copyright holders in Delhi High Court asking for a blanket ban of the sites is not against Sci-Hub and Libgen; it is against the research scholars in this country. Most of whose research would come to a halt if this case by the robber barons of the publishing industry succeeds. It is the future of research in India that is at stake, not Alexandra Elbakyan or Sci-Hub’s future.

AIPSN demands that the monopolistic model of access to knowledge be given up and the process of free access to knowledge by the public accepted.

AIPSN joins hands in support of those legally fighting these monopoly publishing industries against SciHub and Libgen which are working like the story figure of Robin Hood in making the knowledge commons work by providing the public a way to have their right to accessing knowledge.

 

Contact

Rajamanickam, General Secretary AIPSN

gsaipsn@gmail.com, 9442915101

Twitter @gsaipsn

 

Sabka Desh Hamara Desh Campaign

SDHD2 Materials

The All India People’s Science Network (AIPSN) at its All India People’s Science Congress in Bangalore in May 2015 had decided to launch an All India campaign that addresses the twin threats posed by the neoliberal and religious sectarian assault on people’s lives in India.

The contours of the programme were discussed and finalized at a national level cadre camp in July 2016, organized in Panchmari, MP. The campaign, Sabka Desh, Hamara Desh, was launched on November 7th, 2016. A National Advisory committee consisting of eminent personalities drawn from the fields of Science and culture has been formed. The campaign is conceived as a nationwide mass contact programme with a distinct political content.

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